Rejecting Meritorious Candidates on Technicalities is Unjust and Irrational: Delhi High Court

In a landmark judgment, the Delhi High Court has ruled in favor of appellants seeking admission to post-graduate medical courses at Armed Forces Medical Services (AFMS) institutions. The court criticized the rejection of their applications on technical grounds—specifically the absence of an official seal on sponsorship certificates—and directed their admission for the 2024-2025 academic year.

The case revolves around appellants who participated in the NEET-PG exam and sought admission to various AFMS institutions. Despite qualifying, their applications were rejected because their sponsorship certificates lacked the official seal, a requirement not explicitly stated as mandatory in the admissions information bulletin.

The High Court, in its detailed observations, emphasized that the absence of an official seal on the sponsorship certificates was a procedural formality rather than a mandatory requirement. Justice Amit Bansal stated, "If the respondents were of the view that an official seal was mandatory, then this should have been clearly stipulated in the Information Bulletin."

The court noted that in previous years, candidates had been admitted without the official seal on their sponsorship certificates. "The respondents never insisted on the official seal in earlier years, leading the appellants to reasonably believe it was not a mandatory requirement," the judgment read.

Justice Bansal also highlighted the lack of opportunity given to the appellants to rectify the issue. The appellants were only made aware of the deficiency after the merit list was published. The judgment noted that, in past years, a WhatsApp group was created to inform successful candidates about such deficiencies.

The court remarked that if the respondents had any doubts about the authenticity of the sponsorship certificates, they should have verified them with the concerned departments. "The intent behind the requirement of having an office seal is to ensure the genuineness of the sponsorship certificate," the judgment stated.

The judgment extensively discussed that the fixing of the official seal was not a mandatory requirement but a procedural formality. The court cited several precedents, including the Supreme Court's judgment in Dolly Chhanda v. JEE, Chairman, highlighting that procedural lapses should not lead to the denial of admission to otherwise eligible candidates.

The court directed that the appellants, who were unjustly excluded from the merit list, be admitted in the next academic year. "Where authorities have denied admission on wholly unjust and illegal grounds, the candidate should be given admission in the next academic year," the court observed, referencing S. Krishna Sradha v. State of Andhra Pradesh.

Justice Bansal remarked, "The decision to reject the claim of the appellants on the ground of absence of an official seal was wholly arbitrary, unjust, and irrational."

The Delhi High Court's decision underscores the judiciary's role in ensuring fair and just treatment in the admission process for medical courses. By affirming that procedural technicalities should not impede the merit-based admission of candidates, the judgment sets a precedent for future cases, ensuring that genuine candidates are not denied opportunities due to minor administrative lapses.

Date of Decision: 31 May 2024